ACP – Anti-Corruption Policy

The Anti-Corruption Policy of PJ Diesel Engineering A/S. Representatives (“Policy”) prohibits corruption of all officials (clients, vendors, partners, all PJ Diesel Engineering A/S business relations), which means paying money or giving something of value to a official to obtain an improper benefit.

This Policy similarly prohibits the payment of bribes or kickbacks in commercial transactions that do not involve officials. Corruption is prohibited by the laws in almost every jurisdiction of the world. This Policy also prohibits money laundering, which is the process of concealing funds that have been illegally obtained.

PJ Diesel Engineering A/S, and all of its subsidiaries and joint ventures worldwide (“PJ Diesel Engineering A/S”), requires its channel partners (for example, resellers, advisors, original equipment manufacturers, and distributors), consultants, lobbyists, and other third-party representatives (collectively, “PJ Diesel Engineering A/S Representatives”) to comply with this Policy. PJ Diesel Engineering A/S Representatives acting on behalf of PJ Diesel Engineering A/S can expose PJ Diesel Engineering A/S to liability under anti-corruption and anti–money-laundering laws, including the United States Foreign Corrupt Practices Act (“FCPA”). Further, corruption promotes poverty, hunger, disease, and crime, and it keeps societies and individuals from reaching their full potential. Corruption is one of the leading obstacles to economic and social development. PJ Diesel Engineering A/S is committed to observing the standards of conduct set forth in the FCPA and the anti-corruption and anti–money-laundering laws of the countries/regions in which it operates. PJ Diesel Engineering A/S is also committed to taking reasonable steps to ensure that PJ Diesel Engineering A/S Representatives comply with these standards of conduct and laws in its dealings with or on behalf of PJ Diesel Engineering A/S.

1. Compliance with Anti-Corruption LawsEach PJ Diesel Engineering A/S Representative will comply with all applicable anti-corruption laws, including the FCPA. No PJ Diesel Engineering A/S Representative shall, directly or indirectly, offer or pay anything of value (including gifts, travel, entertainment expenses, and charitable donations) to any official or employee of any government, government agency, political party, or public international organization, or any candidate for political office, to (i) improperly influence any act or decision of such official, employee, or candidate for the purpose of promoting the business interests of PJ Diesel Engineering A/S in any respect, or (ii) otherwise improperly promote the business interests of PJ Diesel Engineering A/S in any respect.

2. Vetting of PJ Diesel Engineering A/S ReprensentativesPJ Diesel Engineering A/S will conduct a due diligence or “vetting” of each PJ Diesel Engineering A/S Representative to determine that its relationship with the representative does not pose a risk to PJ Diesel Engineering A/S of noncompliance with this Policy. As part of this process, PJ Diesel Engineering A/S will ask the PJ Diesel Engineering A/S Representative to respond to a questionnaire and, if appropriate, provide additional information that may be necessary in the reasonable judgment of PJ Diesel Engineering A/S. PJ Diesel Engineering A/S appreciates the understanding and cooperation of each PJ Diesel Engineering A/S Representative in this regard.

4. No RetaliationPJ Diesel Engineering A/S Representatives will not retaliate against anyone who has, in good faith, reported a possible violation of this Policy, or refused to participate in activities that violate this Policy.

5. Enforcement PJ Diesel Engineering A/S will enforce this Policy in accordance with the terms of its contracts with PJ Diesel Engineering A/S Representatives.Please do not hesitate to contact us for additional information.